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Kingdom of Norway Deposited on 17 July 2019 Kingdom of Norway Status of List of Reservations and Notifications upon Deposit of the Instrument of Ratification This document contains the list of reservations and notifications made by Norway upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the Convention. 1 Deposited on 17 July 2019 Article 2 – Interpretation of Terms Notification - Agreements Covered by the Convention Pursuant to Article 2(1)(a)(ii) of the Convention, Norway wishes the following agreement(s) to be covered by the Convention: Other Original/ Date of Date of Entry No Title Contracting Amending Signature into Force Jurisdiction Instrument 1 Convention between The Kingdom of Argentina Original 08-10-1997 30-11-2001 Norway and the Republic of Argentina for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital 2 Convention between the Kingdom of Australia Original 08-08-2006 12-09-2007 Norway and Australia for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion 3 Convention between the Kingdom of Bulgaria Original 22-07-2014 30-07-2015 Norway and the Republic of Bulgaria for the avoidance of double taxation with respect to taxes on income 4 Convention between the Kingdom of Chile Original 26-10-2001 22-07-2003 Norway and the Republic of Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 5 Agreement between the Government China Original 25-02-1986 21-12-1986 of the Kingdom of Norway and the Government of the People’s Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 6 Convention between the Kingdom of Cyprus Original 24-02-2014 08-07-2014 Norway and the Republic of Cyprus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 7 Convention between the government Czech Original 19-10-2004 09-09-2005 of the Kingdom of Norway and the Republic Government of the Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 8 Convention between The Kingdom of Estonia Original 14-05-1993 30-12-1993 Norway and The Republic of Estonia for the avoidance of double taxation 2 Deposited on 17 July 2019 and the prevention of fiscal evasion with respect to taxes on income and on capital 9 Agreement between The Kingdom of Georgia Original 10-11-2011 23-07-2012 Norway and Georgia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 10 Convention between The Kingdom of Greece Original 27-04-1988 16-09-1991 Norway and The Hellenic Republic for the avoidance of double taxation and the prevention of fiscal evasion with Amending 06-06-1998 01-01-1999 respect to taxes on income and on notification capital 11 Agreement between the Kingdom of India Original 02-02-2011 20-12-2011 Norway and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 12 Convention between the Kingdom of Ireland Original 22-11-2000 28-11-2001 Norway and Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital 13 Convention between the Kingdom of Japan Original 04-03-1992 16-12-1992 Norway and Japan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income 14 Convention between the Kingdom of Latvia Original 19-07-1993 30-12-1993 Norway and the Republic of Latvia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 15 Convention between The Kingdom of Lithuania Original 27-04-1993 30-12-1993 Norway and The Republic of Lithuania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 16 Overenskomst mellom Kongeriket Luxembourg Original 06-05-1983 27-02-1985 Norge og Storhertugdømmet Luxembourg til unngåelse av Amending 07-07-2009 12-04-2010 dobbeltbeskatning og Protocol skatteunndragelse med hensyn til Amending 25-12-1998 01-01-1999 skatter av inntekt og formue instrument Convention entre le Royaume de Norvège et le Grand-Duché de Luxembourg tendant à éviter les doubles impositions et à prévenir 3 Deposited on 17 July 2019 l’évasion fiscale en matière d’impôts sur le revenu et sur la fortune 17 Convention between the Kingdom of Malta Original 30-03-2012 14-02-2013 Norway and Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income 18 Overenskomst mellom Kongeriket Mexico Original 23-03-1995 23-01-1996 Norge og Mexicos Forente Stater til unngåelse av dobbeltbeskatning og forebyggelse av skatteunndragelse med hensyn til skatter av inntekt og formue1 Convenio entre el reino de Noruega y los Estados Unidos Mexicanos para evitar la doble imposición e impedir la evasión fiscal en materia de impuestos sobre la renta y sobre el patrimonio 19 Convention between the Kingdom of The Original 12-01-1990 31-12-1990 Norway and the Kingdom of the Netherlands Netherlands for the avoidance of double taxation and the prevention Amending 23-04-2013 30-11-2013 of fiscal evasion with respect to taxes Protocol on income and on capital 20 Convention between the Kingdom of Poland Original 09-09-2009 25-05-2010 Norway and the Republic of Poland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Amending 05-07-2012 02-04-2013 Protocol 21 Convention between the kingdom of Portugal Original 10-03-2011 15-06-2012 Norway and the Portuguese republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 22 Convention between the kingdom of Romania Original 27-04-2015 01-04-2016 Norway and Romania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 23 Convention between The Kingdom of Russia Original 26-03-1996 20-12-2002 Norway and The Russian Federation For the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 24 Convention between the Kingdom of Serbia Original 17-06-2015 18-12-2015 Norway and the Republic of Serbia for the Avoidance of Double Taxation 1 Unofficial translation: “Agreement between the Kingdom of Norway and the United Mexican States to avoid double taxation and prevent tax evasion with respect to taxes on income and on capital” 4 Deposited on 17 July 2019 and the Prevention of Fiscal Evasion with Respect to Taxes on Income 25 Convention between the Kingdom of Slovenia Original 18-02-2008 10-12-2009 Norway and the Republic of Slovenia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 26 Convention between the Kingdom of South Africa Original 12-02-1996 12-09-1996 Norway and the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Amending 16-07-2012 20-11-2015 Evasion with respect to taxes on Protocol income 27 Convention between the Kingdom of Turkey Original 15-01-2010 15-06-2011 Norway and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 28 Convention Between The Kingdom of United Original 14-03-2013 17-12-2013 Norway and The United Kingdom of Kingdom Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital gains 5 Deposited on 17 July 2019 Article 3 – Transparent Entities Reservation Pursuant to Article 3(5)(b) of the Convention, Norway reserves the right for paragraph 1 not to apply to its Covered Tax Agreements that already contain a provision described in Article 3(4). The following agreement(s) contain(s) provisions that are within the scope of this reservation. Listed Agreement Number Other Contracting Jurisdiction Provision 11 India Article 4(1)(b) 6 Deposited on 17 July 2019 Article 4 – Dual Resident Entities Reservation Pursuant to Article 4(3)(d) of the Convention, Norway reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements that already address cases where a person other than an individual is a resident of more than one Contracting Jurisdiction by requiring the competent authorities of the Contracting Jurisdictions to endeavour to reach mutual agreement on a single Contracting Jurisdiction of residence, and that set out the treatment of that person under the Covered Tax Agreement where such an agreement cannot be reached. The following agreement(s) contain(s) provisions that are within the scope of this reservation. Listed Agreement Number Other Contracting Jurisdiction Provision 3 Bulgaria Article 4(3) 4 Chile Article 4(3) 6 Cyprus Article 4(3) 8 Estonia Article 4(3) 14 Latvia Article 4(3) 15 Lithuania Article 4(3) 22 Romania Article 4(3) 24 Serbia Article 4(3) 28 United Kingdom Article 4(4) Notification of Existing Provisions in Listed Agreements Pursuant to Article 4(4) of the Convention,Norway considers that the following agreement(s) contain(s) a provision described in Article 4(2) that is not subject to a reservation under Article 4(3)(b) through (d).
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